Complaint and Discovery Requests

8/20/2019 Complaint and Discovery Requests

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IL H BYRD

CUY HOG

COU TY CUERK OF COURTS

1200 Ontario Street

Cleveland, Ohio 44113

urt of mm n Pleas

ew Case Electronically

Filed:

December 21,2015 10:51

By: SU ODH HANDRA 0069233

onfirmation Nbr.

624362

SIMPSON

HUGGINS

vs

THE METROHEALTH SYSTEM

V 15

856035

Judge:

MI HAEL

ASTRAB

Pages Filed:

32

Electronically

Filed 12/21/2015

10:51 /

/

V

15

856035 / onfirmation Nbr.

624362 /

LMKO



IN

THE

OURT OF MM N LEAS

UYAHOGA

OUNTY,

OH

Simps n

Huggins

III

4849

D n van

Street

leveland, OH

44125, ase N .

Plaintiff,

Judge

vs.

The

Metr Health

System

2500

Metr Health

Drive

leveland,

OH

44109,

Defendant.

plaint

with

Jury

D

e and

ature of actio

1.

This

is

an

action

to

rec ver

for retaliation

under

Ohi

’s

Whistlebl wer

Statute,

R. .

4113.52. Plaintiff Simps n Huggins III

was

retaliated against for

rep rting

crimes he

disc vered

while

perf rming his

duties

as

Direct r

of

Internal

Audit

for

The

Metr Health

System.

After

rep rting

these

crimes to the

Audit

mmittee of the B ard of Trustees

including

theft of B t x

injections

and ther

services

fr m

Metr Health

’

s

Pepper

Pike

Dermat l gy

linic

for

use

by

senior

executives

and

irregularities

with

EO Akram

B utr s

’

s

travel

expenses

and ther

reimbursements Mr. Huggins

was

placed n unpaid

administrative

leave in

retaliation for l king at rec rds he “had n business l king at” and “ verstepping

his b unds” as an empl yee (to qu te Metr Health General unsel Michael D.

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856035 onfirmation Nbr. 624362 LMKO



Phillips).

Rather than

address the

issues Mr.

Huggins

raised,

Metr Health ch se to

c me

after

Mr. Huggins.

Such

actions

violate

Ohi law.

Parties

2. Plaintiff Simps n Huggins III is the Direct r of Internal Audit

for

The

Metr Health System. He resides in uyah ga unty.

3. Defendant Metr Health System is a c unty hospital located in uyah ga

unty.

Metr Health

empl yees are

public

empl yees paid by

the

c unty

and

subject

to

Ohi

ethics

laws.

Jurisdiction

and venue

4.

The

urt

has

jurisdiction because

the

suit c ncerns state-law violations

and

the

am unt in

c ntr versy

exceeds $25,000.

5. The urt has pers nal

jurisdiction ver The Metr Health System.

6.

Venue

is

pr per

here

because

the

parties

are

located

in

this

c unty

and

the

events at

issue t k

place here.

Facts

Simpson Huggins becomes Director of nternal udit.

7. Metr Health hired Mr.

Huggins

n appr ximately

June

25,

2012

as

an

audit

manager.

8. In appr ximately March or April

of

2013,

the

Direct r of Internal Audit

resigned. Metr Health put Mr. Huggins in that position n an interim basis.

9. appr ximately July 22, 2013,

Metr Health

made

Mr. Huggins the full

time

Direct r of Internal

Audit.

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10.

The

Direct r of

Internal Audit is resp nsible for a variety

of

duties

including

perf rming an annual financial internal-reporting control

audit.

The

internal-audit

department

c nducts

these

preliminary

tests

as

part of

preparing

for

the

state

auditors to c me in and c nduct their review. Within each

control

testing there are

10-20 individual steps that add up to that control. Part

of

the analysis involves

reviewing acc unts payable for justification as to why expenses are being

reimbursed.

11.

An ther

aspect

of

the

Director

of

Internal

Audit

’

s

duties

is

to

rep rt

to

Metr Health’s

Audit

mmittee

at

quarterly meetings.

Mr.

Huggins has

been

rep rting at these

quarterly meeting

since July

2013.

12. Mr.

Huggins

reports

n

an

administrative

basis

to

hief

Financial

Officer

raig Richm nd.

Mr. Huggins reports functionally to

the

B ard of

Trustees.

Mr

uggins

uncovers

felony

theft

crimes

including

receipt

of

free

Botox

injections

and

other

services

by

certain

senior Metro ealth

employees

and

use of public funds to pay

for

lavish

personal travel

for

the

CEO

13.

As part

of

c nducting his

internal audit,

Mr. Huggins unc vered

a

variety

of

impr per activity and

practices that

constitute felony

theft.

14. One of

the

subjects

of Mr.

Huggins

’

s

audit

was possible fraud and theft at the

Metr Health Pepper Pike Dermat l gy linic. His audit revealed that tw vice

presidents

and at least

ne

empl yee

’

s relative accepted free B t x injections

and

ther services at the Metr Health Pepper

Pike

Dermat l gy linic.1

1 Mr.

Huggins

kn ws

the

names

of the

individuals wh

accepted

these

free

services. And the

d cumentati n

supp rting his audit (which, as described below, Metr Health confiscated)

includes

their

names

as

well.

Mr.

Huggins

is

n t

identifying them

in

this

pleading due to

medical-privacy

concerns.

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15.

Metr Health

empl yees

administered the

free

treatments.

These

empl yees

failed

to

c mply with pr per pr cedures

regarding

rec rding

lot

numbers

and

expiration

dates

for

the

B t x

that

was

administered.

16. The cust mary charge

for

or

value

of a single B t x treatment at the

Metr Health Pepper

Pike

Dermat l gy linic is at least $729.

17. Theft of pr perty or

services

valued at m re than $1,000 is a felony.

18.

B t x is

a

danger us

drug

under

Ohi

law.

19.

Theft

of

a

danger us

drug

is

a

felony.

20. Mr.

Huggins

’s audit

also

revealed

impr per

expenses

including

evidently

pers nal

(non-business) travel

expenses

paid

n behalf

of hief

Executive

Officer

Akram B utr s

and his

wife

including

trips

to

L nd n,

w

Y rk,

Venice,

and

Abu

Dhabi.

These expenditures

exceeded

$1000 each.

21.

Mr.

Huggins

’

s

audit

further

revealed

impr per

pr cedures

regarding

c rp rate

credit-card

usage

and failure

to enforce

the written

policies regarding

submissi n of receipts to

justify

and d cument expenses.

22.

Audit reports typically include ne of the following ratings:

mmendable,

Satisfactory,

Needs

Impr vement,

Needs

Significant

Impr vement,

or

Unsatisfactory.

23. hief

Financial

Officer raig Richm nd

instructed

Mr. Huggins n t

to

sh w

any rep rt ratings in his

presentati n

to the Audit mmittee.

24. Mr. Richm nd

also

instructed Mr.

Huggins

to

withh ld

any Executive

Summaries

for

audit

reports

and n t to

present

the

findings

in Open

F rum.

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25. Mr. Richm nd

further

instructed

Mr.

Huggins

to

present

the

observations,

findings,

and rec mmendati ns nly in

Executive

Session.

Mr.

uggins

blows

the

whistle

on criminal

activity

26. December 15, 2015, Mr. Huggins delivered a presentati n to the Audit

mmittee in which he detailed a variety

of

concerns. Param unt in his rep rt

was

his disc very regarding the B t x theft at the

Pepper

Pike Dermat l gy linic. He

also

c vered

impr per

payment of

pers nal

travel

expenses

for

Dr. B utr s.

27.

During

the

Audit

mmittee

meeting

n

December

15,

2015,

Audit r

Bryan

Licht,

at

Mr.

Huggins

’

s

direction,

sent a

c py

of

the

written

audit rep rt

regarding

the

B t x and impr per B utr s

expenditures

to

raig Richm nd ( hief

Financial

Officer),

Dan Lewis

( hief

Operating

Officer),

Alfred

nners

( hief

Quality

Officer), Abel T rres (Executive Direct r and hairman for Dermat l gy), and

Brendan

Patters n

( linical

Service

Line

Leader

for

Dermat l gy).

28.

Mr.

Huggins exercised due diligence and reas nable care

in

investigating

the

violations he raised

in

his presentati n at the Audit

mmittee

meeting and in his

written audit

report.

The retaliation

begins

while

Mr.

uggins

is

in the

midst

of

reporting

his

findings

to

the

udit

Committee.

29.

During

Mr.

Huggins

’

s

rep rt

to

the

Audit

mmittee,

Metr Health

General

unsel

Michael

D.

Phillips

left

the

meeting

r m.

M ments

later,

Mr.

Huggins

’s

email and

system-netw rk

access

was

terminated.

30.

Mr.

Huggins typically participates in

the

Finance

mmittee meeting that

follows the Audit

mmittee meeting.

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31.

At Audit mmittee

meeting ’s c nclusi n

n December 15,

2015,

Mr.

Huggins

was

preparing

to

participate

in

the

Finance mmittee

meeting

when

hief

Financial

Officer

raig Richm nd

told

Mr.

Huggins

that

he sh uld

n t

participate in the Finance meeting. Mr. Huggins, initially misunderstanding

because he is a regular participant in the Finance mmittee meeting, assured Mr.

Richm nd that he w uld stay and that staying was n t a pr blem. Mr. Richm nd

repeated several times that Mr. Huggins sh uld n t

participate

and that he sh uld

“

just

g

ahead

and

leave.

”

32.

Mr.

Huggins

f ll wed Mr.

Richm nd

’s

unusual instruction and

left

the

meeting area.

uma Resources,

the

General Counsel,

and

a

hospital detective

escort

Mr uggins to the legal department, hassle him about his audit, and place

him

on unpaid administrative

leave

33.

After

leaving

the

meeting

area,

Vice

President

of

H man

Res urces

Deb

Warman,

General unsel

Michael

D.

Phillips,

and a

hospital detective

c nfr nted

Mr.

Huggins

in

the

hallway utside

the

b ardr m.

They asked Mr.

Huggins

to

c me

with

them

to

a

c nference

r m

in

the legal

office.

Mr.

Huggins c mplied

with

that instruction.

34. During

the

meeting in

the

c nference r m in the legal office, Ms. Wa man

told Mr.

Huggins that

there

had been a

c mplaint

ab ut his w rk.

35. Mr. Phillips c mplained that Mr. Huggins

was

l king

at

rec rds that he

“had n business l king at” and

“

verstepping

his b unds” as

an

empl yee.

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36.

Mr.

Phillips

asked Mr.

Huggins

questi ns

ab ut why

he

was

accessing certain

rec rds

ab ut Dr.

B utr s

’s

expenses

and making copies

of

certain

files

regarding

th se

expenditures.

37. In Mr. Huggins ’s capacity as

an

auditor, he reviews financial things like

expenses pr cessed thr ugh acc unts payable. Mr. Huggins explained that, under

the Internal Audit harter, the Audit mmittee of the Metr Health B ard of

Trustees

has granted

permissi n

for

his

department

to review all d cuments and

records,

b th

pers nal

and

property,

within

the

system.

38.

Mr.

Phillips

asked Mr.

Huggins

why he used

a flash

drive

to

store

files when

he had rem te access.

39.

Mr.

Huggins

explained

that

he

used a flash drive because he had b th

a

deskt p

and a lapt p c mputer and

the

flash drive all wed him to easily transition

between

the

two.

40.

Mr.

Phillips

asked Mr.

Huggins

if

he

was

aware

of

any

illegal activity that

Mr. Phillips

sh uld

be

made

aware

f.

41.

In

resp nse,

Mr.

Huggins reiterated his

earlier

reports and also referenced

Mr.

Phillips’

s

practice

of

signing

the

invoices

to appr ve payment to his

wn

private

law

firm.

42.

Mr.

Phillips told

Mr.

Huggins that

he

was

being

placed

n administrative

leave

pending

an “investigation.”

43. Ms.

Wa an

inf rmed Mr.

Huggins that

the

administrative leave w uld be

unpaid.

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44.

Mr.

Huggins

asked Ms.

Wa man

if

he w uld use pers nal time

off (PTO)

during

the

leave

(as

he was

aware

ther empl yees

had

been

permitted to

do).

The

head

of

H man

Res urces

said that she did n t

kn w

if

Mr.

Huggins

c uld use PTO

for

this

purp se.

45.

At

the meeting ’s conclusion, Ms. Wa man confiscated Mr. Huggins ’s keys to

his office and desk, his hospital ID, his silver SanDisk ruzer flash drive, and the

materials fr m the audit meeting

that Mr. Huggins

had in

his

possession.

46.

Bef re

being

escorted

off

of

hospital

property,

Mr.

Huggins

was

n t

permitted

to retrieve

pers nal

items fr m his

office.

Claim

:

Whistleblower Retaliation under R C 4113 52( )

47.

Plaintiff

inc rp rates

all

previ us

allegations.

48.

In the c urse

of

Mr. Huggins ’s empl yment, he

became

aware

of crimes that

Metr Health had

the

auth rity

to

correct.

49.

In

the

c urse of

Mr.

Huggins

’s

empl yment,

he became aware

of

violations

of

state law by fellow empl yees.

50. Mr.

Huggins

made

reas nable and good-faith

efforts

to determine the

accuracy of the inf rmati n he reported.

51.

Mr.

Huggins

reas nably

believed

that

the

c nduct

he

identified

during

the

Audit mmittee meeting and in his audit report regarding the theft of B t x

was

a

felony.

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52.

Mr.

Huggins

reas nably

believed that

the

c nduct he identified during

the

Audit

mmittee

meeting

and

in

his

audit

report

regarding

Dr.

B utr s a

public

empl yee

accepting

payment for

pers nal

travel

expenses

was a felony.

53. December 15, 2015, Mr. Huggins gave a presentati n to the Audit

mmittee of the B ard of Trustees in which he notified resp nsible officers of the

violations.

54.

Mr. Huggins ’s oral

rep rt

at

the Audit mmittee meeting satisfied the

oral-

report

requirements

of

R. .

4113.52(A)(1)(a).

55.

Mr.

Huggins

’s oral

rep rt

at

the

Audit

mmittee

meeting

satisfied

the

oral-

report

requirements

of

R. . 4113.52(A)(3).

56.

Mr.

Huggins

also

sent

a

written

a

written

rep rt pr viding

sufficient

detail to

identify and describe

the

violations to

the

following resp nsible

officers:

raig

Richm nd

( hief

Financial

Officer);

Dan

Lewis

( hief

Operating

Officer);

Al

nners ( hief

Quality Officer); Abel T rres

(Executive Direct r and

hairman for

Dermat l gy);

and Brendan Patters n

( linical

Service Line Leader

for

the gr up

ver

Dermat l gy).

57.

Mr.

Huggins

’s written

audit

rep rt

satisfied the

written-report

requirements

of

R. . 4113.52(A)(1)(a).

58.

Mr.

Huggins

’s written

audit

rep rt

satisfied the

written-report

requirements

of R. . 4113.52(A)(3).

59. Rather than make a good-faith effort to correct the violations

Mr.

Huggins

reported,

Metr Health

placed him n

unpaid

administrative

leave.

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60.

Mr.

Huggins

was

n t

permitted

to use

T during his administrative leave.

61.

Metr Health

retaliated

against

Mr.

Huggins

because he rep rted criminal

activity.

62. As a direct and pr ximate result

of

Metr Health’s illegal actions, Mr.

Huggins has suffered ec n mic and n n-ec n mic damages in

an

am unt to be

determined at trial.

63.

Mr. Huggins is entitled to punitive

damages

based

n Metr Health’s

intentional

and

malici us

acts.

P ye fo el ef

F r

the

reas ns

state ab ve,

Plaintiff

respectfully requests

the

following relief

fr m

the

ourt:

A. Declare that Defendants acts

and c nduct

constitute

violations

of Ohi

law;

B. Enter judgment in Plaintif

f

s fav r as to all claims for relief;

. Award Plaintiff full c mpensat ry damages, ec n mic and n n-ec n mic,

including,

but

n t

limited to, back pay,

front

pay, damages

for

pain and

suffering,

mental

anguish,

em ti nal

distress,

humiliation,

and

inc nvenience

that Plaintiff

has

suffered and is

reas nably

certain

to

suffer

in

the

future;

D.

Award

Plaintiff

punitive

damages

for intentional

and

malici us violations

of

Ohi

law;

E.

Award

pre-judgment

and

p st-judgment

interest at

the

highest

lawful

rate;

F.

Award

Plaintiff

his

reas nable

att rneys

fees

(including expert fees)

and

all ther costs of suit;

G.

Order

Metr Health

to

return Mr.

Huggins

’s

pers nal

property;

H.

Award

all ther relief in law or equity to which Plaintiff is

entitled and

that

the urt deems equitable,

just,

or

proper.

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Jury

dem d

Plaintiff demands

a trial

by

jury n all issues within this mplaint.

Dated: December 21,

2015

Respectfully submitted,

Subodh C an ra_ _ _ _ _ _ _ _ _ _ _ _

Sub dh

handra (0069233)

Ashlie

ase

Sletvold

(0079477)

Harris n

Blythe

(00093851)

THE

HANDRA

W FIRM, LL

1265

W. 6

th St.,

Suite 400

leveland,

OH

44113-1326

216.578.1700 Ph ne

216.578.1800 Fax

Sub dh. handra@ handraLaw.c m

Ashlie.Sletv ld@ handraLaw.c m

Harris n.Blythe@ handraLaw.c m

Attorney

for Plaintiff

Simp on Huggin

III

equest

for

ervice

T

the

clerk:

Please

issue

the

Summ ns

and mplaint and

serve the

mplaint

and

acc mpanying disc very requests

at

the addresses listed ab ve, making

return

acc rding

to law.

Subodh

C an ra

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

One

of

the attorney for

Plaintiff Simp on Huggin III

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mailto:[email protected]








IN

THE

OURT OF MM N LEAS

UYAHOGA

OUNTY,

OH

Simpson

Huggins

III

Plaintiff, ase No.

vs.

Judge

The MetroHealth System

Defendant.

P intiff

First et of Requests for dmission Directed to Defend nt

T

he Metro

e th ystem

under

Ohio C

iv

R 36

Under Ohio Rule of ivil Procedure 36, Plaintiff requests that Defendant

respond

to Plaintiff’s First Set of Requests for Admission within 8 days

of

service.

These

requests

are

to

be

answered

completely

and

fully,

in

writing,

and

under

oath.

f

timely

responses

are

not

received,

the

requests

will

be admitted

consistent

with iv.R. 36.

STRUCT O S

A. Definitions. In answering each request, use the following definitions:

1. The word “MetroHealth” refers to Defendant The MetroHealth System.

2.

“And

”

and

“or”

shall be construed

either

disjunctively

or

conjunctively

as

necessary

to

bring

within

the

scope

of

the

request

all

responses

that might

otherwise

be

construed to

be

outside its

scope.

3.

“Any

”

includes the

word

“all,

”

and “all” includes

the

word

“any.

”

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B.

These

requests

for admissi n shall be

deemed

c ntinuing

in nature and

are

to

be

supplemented

as

additional

inf rmati n pertinent to any request is obtained,

including,

but

n t

limited

to,

additional

inf rmati n that adds to

a previ us

resp nse, corrects a previ us resp nse, and/ r clarifies a previ us response.

. If objection is made, the reas ns

for

y ur objection shall be stated.

The

answer shall specifically deny the matter or set forth in detail the reas ns why y u

cann t

truthfully

admit

or

deny

the matter. A denial

shall fairly

meet the substance

of

the

requested

admissi n,

and

when

g d

faith

requires

that

y u

qualify

y ur

answer,

or

deny

nly

a part of

the

matter

of

which an

admissi n

is

requested,

y u

shall

specify so

much of

it as

is

true and

qualify or

deny

the

remainder.

Y u

y

n t

give lack of

inf rmati n or kn wledge

as

a

reas n

for

failure to

admit

or deny

unless

y u state that y u have

made

reas nable inquiry and that

the

inf rmati n

kn wn

or

readily

btainable

by

y u

is

insufficient

to

enable

y u

to

admit

or

deny.

If

y u

c nsider

that

a

matter

of

which

an

admissi n has been

requested presents

a

genuine issue for trial, y u y not, n that gr und alone, object to the request; y u

may,

subject to the provisions of

iv.R. 37( ),

deny

the matter

or

set

forth

reas ns

why y u cann t

admit

or

deny

it.

REQUESTS

FOR

DMISSIO

1.

Admit

that

Simps n

Huggins

as

of

December

15,

2015 was

the Director

of

Internal Audit

for

Metr Health.

RESPO SE:

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2. Admit that in December

2015,

Metr Health General

unsel Michael D.

Phillips told Simps n Huggins that he had “n business l king at” records

regarding expenditures for Metr Health

hief

Executive Officer Akram

B utr s.

ESPO SE:

3.

Admit that

in

December 2015,

Metr Health

General

unsel

Michael D.

Phillips

told Simps n

Huggins

that

he

had

“

verstepped

his

b unds”

regarding

his audit of

expenditures

for

Metr Health

hief

Executive Officer

Akram B utr s.

ESPO SE:

4.

Admit

that

n

December

15,

2015,

Metr Health

placed

Simps n

Huggins

n

unpaid

administrative leave.

ESPO SE:

5.

Admit

that

Metr Health

pr m ted

Simps n

Huggins

to

the

position

of

Direct r of Internal Audit n appr ximately July 22,

2013.

ESPO SE:

6. Admit that

ne of

Simps n

Huggins

’s

duties as the

Direct r

of

Internal Audit

is

perf rming

an

annual

financial

internal

rep rting

control

audit.

ESPO SE:

7. Admit that

ne

of Simps n Huggins ’s duties as the Direct r of

Internal Audit

is rep rting to

the

Audit mmittee of

the B ard of

Trustees

regarding

the

results of his auditing activity.

ESPO SE:

8. Admit that n December

15,

2015,

Simps n

Huggins

made

a

presentati n

to

the

Audit

mmittee

of

the

B ard

of

Trustees.

ESPO SE:

9.

Admit that n December 15, 2015,

Simps n Huggins rep rted to

Michael

Phillips,

Dan

Lewis,

Alfred

nn rs,

raig

Richm nd,

Abel Torres,

Brendan

Patterson,

and Mary Legerski that he had unc vered

theft

at

the

Metr Health Pepper Pike Dermat l gy linic.

ESPO SE:

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10. Admit that

n December

15,

2015,

Simps n

Huggins

rep rted

to

Michael

Phillips,

Dan Lewis, Alfred nn rs, raig Richm nd, Abel Torres, Brendan

Patterson,

and

Mary

Legerski that he had

unc vered

theft at the

Metr Health

Pepper

Pike

Dermat l gy

linic,

including

the

fact

that

tw

Metr Health

vice

presidents

had

received

free

B t x injections.

ESPO SE:

11.

Admit that n December

15,

2015,

Simps n

Huggins

rep rted to

Michael

Phillips,

Dan Lewis, Alfred

nn rs,

raig

Richm nd, Abel Torres,

Brendan

Patterson, and

Mary

Legerski that he had

unc vered

theft at the

Metr Health Pepper

Pike

Dermat l gy linic, including the fact that a

relative

of

a Metr Health

resident

had received free B t x injections.

ESPO SE:

12.

Admit that n

December

15,

2015,

Simps n

Huggins

rep rted

to

Michael

Phillips,

Dan

Lewis,

Alfred nn rs, raig Richm nd, Abel Torres,

Brendan

Patterson,

and

Mary

Legerski

and

that he

had unc vered theft

at

the

Metr Health Pepper

Pike

Dermat l gy linic,

including

the fact that

the

Metr Health

empl yee

administering free B t x injections had failed to

rec rd the lot number and expiration dates for the vials used.

ESPO SE:

13.

Admit

that

the

standard

charge

for

a

single

B t x

treatment

at

Metr Health

Pepper

Pike

Dermat l gy

linic

is

appr ximately

$729.

ESPO SE:

14. Admit that theft of

pr perty or services valued at m re than $1,000 is

a

felony.

ESPO SE:

15.

Admit that B t x is

a

“

danger us

drug

”

as

that

term

is used

in

Ohi ’s theft

statute,

R. .

2913.02.

ESPO SE:

16. Admit that theft of a “danger us

drug

”

(as that

term

is used in Ohi

’s

theft

statute, R. . 2913.02) c uld

be c nsidered a felony.

ESPO SE:

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17. Admit that

Dr.

B utr s

’s

kn wing receipt of

public hospital funds

to pay for

pers nal travel

expenses

c uld be c nsidered a felony.

ESPO SE:

18. Admit that during

Simps n

Huggins ’s

presentati n

to the

Audit mmittee

of the B ard of Trustees

n

December 15,

2015,

Simps n Huggins

rep rted

that he had unc vered impr per controls by

Metr Health

executives.

ESPO SE:

19.

Admit

that

during

Simps n

Huggins

’

s

presentati n

to the

Audit mmittee

of the B ard of Trustees n

December

15, 2015,

Simps n Huggins

rep rted

that he had unc vered impr per pr cedures regarding c rp rate credit-card

usage.

ESPO SE:

20. Admit that during Simps n Huggins ’s presentati n to the Audit

mmittee

of the B ard

of Trustees

n

December 15,

2015,

Simps n

Huggins

rep rted

that he

had

unc vered

failure

to enforce written policies regarding

submissi n of

receipts

to justify and

d cument expenses.

ESPO SE:

21.

Admit

that

n

December

15,

2015,

Bryan

Licht,

at

Simps n

Huggins

’

s

direction,

emailed

a

c py

of

Mr.

Huggins

s

written

audit

report

regarding

B t x theft and impr per expenditures n behalf of

Dr.

B utr s

to raig

Richm nd, Dan Lewis, Al nners, Abel Torres, and Brendan Patterson.

ESPO SE:

22. Admit that

Simps n

Huggins

exercised

due

diligence

and reas nable care in

investigating

the violations he

raised

in his

presentati n

at

the

Audit

mmittee meeting n December

15, 2015 and in his

written

audit report

pr vided that same day.

ESPO SE:


the Audit mmittee meeting n December 15, 2015,

Metr Health terminated Simps n Huggins

’s

email access.

ESPO SE:

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24. Admit that

during

the c urse

of

his empl yment with

Metr Health,

Simps n

Huggins typically attended the Finance

mmittee

meeting that follows the

Audit

mmittee

meeting.

ESPO SE:

25.

Admit that n December

15,

2015,

hief

Financial

Officer

raig

Richm nd

repeatedly told Simps n Huggins that he sh uld

n t

participate in

the

Finance mmittee meeting

that

day.

ESPO SE:

26. Admit that following

the Audit mmittee

meeting

n December

15, 2015,

hief Financial Officer raig Richm nd told

Simps n Huggins that he sh uld

“

just

g

ahead

and

leave

”

and

n t

participate

in

the

Finance

mmittee

meeting

that

day.

ESPO SE:

27.

Admit that following

the Audit mmittee

meeting

n December

15, 2015,

Vice

President for H man Res urces Deb Wa man and General unsel

Michael Phillips

met

with Simps n Huggins.

ESPO SE:

28.

Admit

that

during

the

meeting

with

Simps n

Huggins,

Deb

Warman,

and

Michael

Phillips

n December 15, 2015,

Mr. Phillips

questi ned

Mr.

Huggins

ab ut why he was

accessing

certain

records.

ESPO SE:

29. Admit that

during

the

meeting with

Simps n

Huggins,

Deb

Warman,

and

Michael Phillips n

December 15, 2015,

Mr. Phillips questi ned Mr. Huggins

ab ut why he was c pying certain files.

ESPO SE:

30.

Admit

that

during

the

meeting

with

Simps n

Huggins,

Deb

Warman,

and

Michael Phillips n December 15, 2015, Mr. Phillips questi ned Mr. Huggins

ab ut why

he

was

using

a flash drive.

ESPO SE:

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31.

Admit that

during

the

meeting with

Simps n

Huggins,

Deb

Warman,

and

Michael Phillips n December 15,

2015,

Mr. Phillips and/ r Ms. Wa an

confiscated Mr. Huggins ’s

flash drive.

ESPO SE:

32.

Admit that during

the meeting

with

Simps n Huggins,

Deb Warman,

and

Michael Phillips n

December

15,

2015,

Mr. Phillips and/ r Ms. Wa an

confiscated

Mr.

Huggins

’

s

hospital

identification card.

ESPO SE:


the meeting

with

Simps n Huggins,

Deb Warman,

and

Michael Phillips n December 15, 2015,

Mr. Phillips

and/ r Ms. Wa an

confiscated

Mr.

Huggins

’

s

keys

to

his

office

filing

cabinet.

ESPO SE:

34. Admit that during the meeting with Simps n Huggins, Deb

Warman,

and

Michael

Phillips


Mr. Phillips

and/ r Ms.

Wa an

confiscated d cuments Mr.

Huggins had received

during

the Audit

mmittee

meeting.

ESPO SE:

35.

Admit

that

during

the

meeting

with

Simps n

Huggins,

Deb

Warman,

and

Michael

Phillips

n

December

15,

2015,

Mr.

Phillips

asked

Mr.

Huggins

if

there

was

any illegal activity of which Mr. Phillips sh uld

be

aware.

ESPO SE:

36. Admit that during the meeting with Simps n Huggins, Deb Warman, and

Michael

Phillips


in

resp nse

to Mr.

Phillips’s

questi n

ab ut

whether

was

any

illegal activity of

which

he sh uld be aware, Mr.

Huggins

resp nded

by

referencing

the

B t x theft

and

Mr.

Phillips’

s practice

of

signing

the invoices to

appr ve

payment

to

his

wn

law

firm.

ESPO SE:


the meeting with Simps n Huggins, Deb Warman, and

Michael Phillips n December 15, 2015,

Mr.

Phillips

and/ r Ms. Wa an told

Mr. Huggins that he

was

being placed n unpaid

administrative

leave.

ESPO SE:

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38.

Admit that

n December

15,

2015,

Metr Health placed

Simps n

Huggins

n

unpaid

administrative

leave.

ESPO SE:

39.

Admit that following the

meeting with

Simps n

Huggins,

Deb

Warman,

and

Michael Phillips

n

December 15, 2015,

Mr. Huggins

was

esc rted

fr m the

building

with ut

being permitted to retrieve his pers nal items fr m his

office.

ESPO SE:

40. Admit that Simps n Huggins

c nducted

internal audits

at

Metr Health

in

the c urse of his empl yment.

ESPO SE:


the

c urse

of

Simps n Huggins ’s empl yment, he became

aware of crimes that Metr Health had

the

auth rity to correct.

ESPO SE:

42.

Admit that during the c urse of

Simps n

Huggins

’s

empl yment, he became

aware

of

violations by state

law by fellow

empl yees.

ESPO SE:

43. Admit that Simps n Huggins made

reas nable

and good-faith efforts to

determine

the

accuracy of

the

inf rmati n that

he

rep rted to Metr Health

n December 15,

2015.

ESPO SE:

44.

Admit that it was reas nable for

Simps n

Huggins

to

believe that the theft of

B t x and ther services fr m the Metr Health Pepper

Pike

Dermat l gy

linic

was

a felony.

ESPO SE:

45.

Admit

that

it was reas nable for

Simps n

Huggins to

believe that the use

of

public hospital funds to pay for Dr.

B utr s’

s

pers nal travel

expenses

was

a

felony.

ESPO SE:

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46.

Admit that

n December

15,

2015,

Simps n

Huggins

orally

notified

resp nsible

officers at Metr Health of potential felony criminal activity.

ESPO SE:

47.

Admit that Simps n

Huggins ’

s

presentati n

to

the Audit

mmittee

n

December

15,

2015

satisfied the

oral-report requirements

of

R. .

4113.52(A)(1)(a).

ESPO SE:

48.

Admit

that

Simps n

Huggins ’

s

presentati n

to

the

Audit

mmittee

n

December 15, 2015

satisfied the oral-report

requirements

of

R. . 4113.52(A)(3).

ESPO SE:

49. Admit that Simps n Huggins ’

s

written audit

report

transmitted n

December

15, 2015 satisfied

the

written-report

requirements of R. . 4113.52(A)(1)(a).

ESPO SE:

50.

Admit that

Simps n

Huggins ’

s

written

audit

report transmitted n December

15,

2015 satisfied the written-report

requirements

of R. .

4113.52(A)(3).

ESPO SE:

51. Admit that General unsel Michael D. Phillips is

a

“resp nsible officer” of

Metr Health

as

that term

is used

in

R. .

4113.52(A)(1)(a) and R. .

4113.52(A)(3).

ESPO SE:

52.

Admit that hief

Operating

Officer Dan Lewis is a

“

resp nsible

officer

” of

Metr Health as that term is used

in

R. .

4113.52(A)(1)(a) and R. .

4113.52(A)(3).

ESPO SE:

53.

Admit

that

hief

Quality

Officer Alfred

nn rs

is

a

“

resp nsible

officer

”

of

Metr Health

as that term is used

in

R. .

4113.52(A)(1)(a) and R. .

4113.52(A)(3).

ESPO SE:

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54.

Admit that hief

Financial

Officer

raig

Richm nd

is a

“

resp nsible

officer”

of Metr Health as that term is used in R. . 4113.52(A)(1)(a) and R. .

4113.52(A)(3).

ESPO SE:

55.

Admit that

Executive

Direct r and

hairman

for Dermat l gy Abel

T rres

is

a

“resp nsible officer” of

Metr Health

as that term is used in R. .

4113.52(A)(1)(a) and R. .

4113.52(A)(3).

ESPO SE:

56. Admit that linical Services

Line

Leader Brendan Patters n is

a

“resp nsible

officer” of Metr Health as that term is used in R. . 4113.52(A)(1)(a) and R. .

4113.52(A)(3).

ESPO SE:

57. Admit that hief mpliance Officer

Mary

Legerski is a “resp nsible officer

”

of

Metr Health as

that

term

is

used in

R. .

4113.52(A)(1)(a)

and

R. .

4113.52(A)(3).

ESPO SE:

58.

Admit that

Simps n Huggins ’

s

written

audit

report

n

December

15,

2015

pr vided

sufficient

detail

to

identify

and

describe

the

potential

felony

criminal

activity

he

had

unc vered

during

his audit.

ESPO SE:

59.

Admit that

Metr Health

retaliated against

Simps n

Huggins because he

rep rted felony criminal activity.

ESPO SE:

60.

Admit that

Metr Health

did

n t

notify

Simps n

Huggins, in writing,

of

any

effort

of

Metr Health

to

correct the violations

he

had reported.

ESPO SE:

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December 21, 2015


Subodh

Chandra

_ _ _ _ _ _ _ _ _ _ _ _

Sub dh

handra

(0069233)

Ashlie

ase

Sletvold

(0079477)

Harris n Blythe

(00093851)

THE

HANDRA

W

FIRM,

LL

1265 W. 6th St., Suite 400

leveland, OH

44113-1326

216.578.1700

Ph ne

216.578.1800

Fax




Coun el for

Plaintiff

Simp on

Huggin

III

ertificate

of ervice

I

certify

that the ab ve

disc very requests

were

submitted

to the lerk’s

Office to

be

served with the Summ ns

and mplaint.

bodh

Chandra

_ _ _ _ _ _ _

One of the

attorney

for

Plaintiff

Simp on

Huggin

III

Page

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IN

THE

OURT OF MM N LEAS

UYAHOGA

OUNTY,

OH

Simpson

Huggins

III

Plaintiff, ase No.

vs.

Judge

The MetroHealth System

Defendant.

P intiff First et of equests for Production of ocuments irected

to efend nt

T

he

Metro e th ystem

under

Ohio

iv

6

Under Ohio Rule of ivil Procedure 34, Plaintiff requests that Defendant

respond

to

Plaintiff’s

First Requests for

Production

of

Documents within 28

days

of

service.

instructions

A.

Definitions. In

answering

each request,

use the following definitions:

1. The

words

“you

”

or “MetroHealth

”

refer

to

Defendant The MetroHealth

System, the party responding to these requests, and/or its agents, employees,

attorneys, representatives, and/or assigns.

2.

The

terms

“document,”

“documents,

” “record,”

or

“

records

”

mean

the

original and

a copy,

regardless

of origin

or

location,

of

any

writing or

records of

any

type

or

description,

whether official

or

unofficial,

including,

but

not limited to,

the

original

and any copy of

any

book,

pamphlet,

periodical, letter, memorandum,

telegram,

report,

record, study,

inter- or intra-office communication,

handwritten

or

Page

1

of

10

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ther

note,

w rking

paper,

publication,

permit,

ledger

and/ r

journal,

whether

general

or

special,

chart,

paper, graph,

survey,

index tape,

disk,

data

sheet,

or

data-

pr cessing card,

or

any

ther

written,

recorded,

transcribed,

filed,

or graphic

matter, h wever pr duced or repr duced, to which Defendant had access or n w has

access. “D cument” or “d cuments” also includes any magnetically, mechanically,

and/ r electronically stored, maintained, and/ r rec rded data, whether the

data

consists of

w rds, symb ls,

numbers,

graphs,

or

ther matters,

including

but

n t

limited

to

email.

3.

“

And

”

and “or

”

shall

be c nstrued

either

disjunctively or conjunctively

as

necessary

to bring within

the

sc pe of

the

request all resp nses

that might

therwise

be c nstrued to be

utside

its

scope.

4.

“Any

” includes

the

w rd “all,” and “all” includes

the

w rd “any.

”

5.

“

Regarding

”

means

relating

to,

c ncerning,

containing,

consisting

f,

referring

to,

reflecting,

supporting,

dem nstrating, sh wing,

identifying,

menti ning,

contradicting,

prepared

in

c nnecti n with, used

in

preparati n for,

pertaining to, having any

relationship

to, evidencing, constituting evidence f, or

being

in any

way

legally,

logically,

or factually

c nnected

with

the

matter

discussed.

B.

These

requests

seek

electronic c mmunicati ns

n t nly

fr m w rk email

addresses but

also

pers nal

email

addresses.

. F r each request or part of a request that Defendant refuses to answer n

gr unds of

burdens meness,

state:

1.

The

number of files and/ r

d cuments

needed

to

be

searched;

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2.

The location of such files; and

3. The

appr ximate

time it w uld

take

to c nduct a

search

for

the

requested

information.

D. These requests

for

pr ducti n shall be deemed c ntinuing in nature and

Defendant’s resp nses are to be supplemented as additional inf rmati n or

d cuments pertinent to a request is btained or created, including, but n t limited

to, additional inf rmati n

that

adds

to

a

previ us resp nse, corrects

a

previ us

resp nse,

and/ r

clarifies

a

previ us

response.

E. Privileges

1. F r each

request

or

part

of

a request that Defendant refuses

to

answer

n gr unds

of

privilege,

state:

a. The

specific

privilege asserted;

b.

The

basis

for

the

privilege;

and

c.

The

identity

of the d cuments

and/ r

inf rmati n

claimed

to

be

privileged.

F.

Inf rmati n

requested

is any and all inf rmati n within the kn wledge of

Defendant resp nding to these

requests

and/ r

its

agents,

empl yees,

attorneys,

representatives,

and/ r

assigns.

G.

Plaintiff

requests that,

to preserve paper and reduce c pying costs,

where

feasible, d cuments resp nsive to the requests bel w be pr vided n D, n t in a

hard-c py paper f rmat.

Plaintiff

requests that,

with the excepti ns

n ted bel w,

each

page of

each

d cument

be

Bates-stamped

for

identification.

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of

10

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H.

S me

of these requests

are

directed to electronically

stored information,

including emails and

w rd-pr cessing

d cuments

stored n Defendant

’s

c mputers,

where practical,

resp nsive

inf rmati n

sh uld

be pr duced in

native

f rmat, n t

c nverted to images or printouts. Plaintiff d es n t require that such d cuments be

pr duced with Bates-stamps, pr vided each d cument has a unique file name. In

the event of high costs of pr ducti n costs

(exceeding

$250), Plaintiff requests that

Defendant

’s c unsel appr ach

Plaintiff’s

c unsel to

confer

regarding

cost-saving

or

cost-sharing

measures

(including

narr wing

the

bel w

requests)

bef re

g ing

f rward with production.

requests

for product o

of

docume s

Please pr duce

the

following:

1.

F r

each

request

for admissi n

that

y u

denied, pr vide

all

d cuments that

tend to

supp rt y ur denial.

ESPO SE:

2.

The

internal

auditing

control

rep rt

prepared

by Simps n Huggins and

transmitted

by email fr m Bryan Licht to raig

Richm nd, Dan Lewis,

Al

nners,

Adel

Torres,

and Brendan

Patters n

at appr ximately

1:00 p.m. n

December

15,

2015.

ESPO SE:

3. Rec rds Simps n

Huggins

relied on, reviewed,

or referenced to prepare

the

internal

auditing

control

rep rt

referenced in

Request

N .

2 above.

ESPO SE:

4.

Rec rds

confiscated fr m Simps n Huggins by Deb Wa man (Vice President

of H man

Res urces)

yesterday

during

the meeting

where

he

was

put

n

unpaid

administrative

leave

including

the

following:

a.

ntents

of

Simps n

Huggins

’

s flash drive (a

silver

Sandisk

attached

to his lanyard with his hospital ID);

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b. Rep rts

for

audit

c mmittee,

rep rt for finance c mmittee,

rep rt that

RMS (external auditors) gave, c mpliance department update; and

HI AA privacy update.

ESPO SE:

5. Rec rds

regarding

the

theft

of

B t x and/ r services

relating

to

B t x

injections

(or ther injectables) pr vided with ut charge to Metr Health

empl yees

or relatives

of

Metr Health

empl yees (patient-identifying

inf rmati n ay

be redacted;

dates of

service, pr viding physician, and

location

are

n t

exempted and must be

made

available).

ESPO SE:

6.

Rec rds

regarding

trips

taken

by

Dr.

Akram

B utr s

and/ r

his

wife

that

were funded by Metr Health or the Metr Health F undati n (including trips

to

Venice,

L nd n, New

Y rk, and

Abu

Dhabi).

ESPO SE:

7.

Rec rds

regarding

any expenditures by

Metr Health

n Dr.

B utr s

’

s

behalf

related

to

his

New

Y rk

medical

license (including

expenses

for m nthly trips

to New

Y rk

to meet the

requirements

to maintain

his

out-of-state

medical

license).

ESPO SE:

8.

Rec rds

regarding

any ther expenditures by

Metr Health

n Dr. B utr s’s

behalf.

ESPO SE:

9. Rec rds

regarding misuse of

Metr Health credit cards by Metr Health

empl yees fr m July 2013-the

present.

ESPO SE:

10.

Rec rds

regarding

failure

to

follow

Metr Health

pr cedures

regarding

payment of credit-card

bills

with ut pr per

receipts

or

d cumentati n

that

the expenditures were appr priate fr m July 2013-the present.

ESPO SE:

11. Rec rds regarding

the

Audit mmittee

meeting

held yesterday at n n

including n tes

taken

by any participant.

ESPO SE:

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12. Rec rds

regarding

the

decision to curtail

Simps n

Huggins

’s

email or

c mputer access and the implementati n of that decision (including all

c mmunicati ns

such as

emails

or

text

messages).

ESPO SE:

13. Rec rds

regarding

the

decision

to

exclude

Simps n

Huggins

fr m

the

Finance

mmittee

meeting that

immediately

f ll wed

yesterday

’s Audit mmittee

meeting (including

all

c mmunicati ns

such

as

emails

or text

messages).

ESPO SE:

14. The entire

c ntents

of

Simps n Huggins ’s

Metr Health

“

drive.”

ESPO SE:

15. Simps n Huggins ’s

emails (current and archived)

fr m July 2013 to the

present

including emails between or am ng Mr. Huggins and

each

of the

following:

a.

General

unsel

Michael Phillips;

b. Vice President

of

linical Integrated

Operati ns

Dean

R berts n;

c.

Executive Direct r/ hairman Dermat l gy Abel Torres;

d.

Audit

mmittee

hairman

J.B.

Silvers;

e. f rmer

Audit

mmittee

hairman R n F untain;

f. Seni r

Vice President and

hief

Financial

Officer

raig Richm nd; and

g.

Ass ciate General

unsel

S nja Rajki.

ESPO SE:

16. Any internal audit charter applicable to Simps n Huggins w rk

at

Metr Health.

ESPO SE:

17. J b description for Director,

Internal Audit.

ESPO SE:

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18. G vernance rules

and regulati ns

regarding

the

functions

of

the

B ard of

Trustees.

ESPO SE:

19. Finalized

Internal

Audit

reports

and

management

plans

fr m January 2012

to

the

present.

ESPO SE:

20.

All empl yee

expense

files

submitted

to

Simps n

Huggins by

A a da Gibs n

(Director, Acc unting for Disbursements) and/ r

David

rt (Staff

Acc untant) fr m 2012-2015 for Financial Rep rting ntr ls testing.

ESPO SE:

21. Daily visit summaries for Pepper Pike Dermat l gy linic fr m 2013-the

present.

ESPO SE:

22.

Listing

and schedule of residents for Pepper Pike Dermat l gy linic fr m

2013-the present.

ESPO SE:

23.

All

rec rds

regarding

the

decision

to

place

Simps n

Huggins

n

unpaid

administrative

leave (including all c mmunicati ns such as emails

or

text

messages).

ESPO SE:

24. Dr. Akram B utr s’s c mpensati n contracts (including any drafts).

ESPO SE:

25. Dr. Akram B utr s

’s

empl yment contracts

(including any drafts).

ESPO SE:

26.

Empl yee

expense

reimbursements

for Akram B utr s.

ESPO SE:

27.

Rel cati n

expenses paid

by

Metr Health

for

Akram

B utr s (both

m ves).

ESPO SE:

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28. Rec rds

regarding any policies

n empl yee

use

of Metr Health credit

cards.

ESPO SE:

29.

Simps n

Huggins ’s pers nnel rec rds including his pers nnel file

and

any

rec rds

that

w uld

typically

be kept

in

a

pers nnel

file (whether Metr keeps

such

rec rds in

an

empl yee ’

s

pers nnel

file

or

not).

ESPO SE:

30.

Pers nnel rec rds including pers nnel

files

and

any

rec rds that w uld

typically

be kept in a

pers nnel

file

(whether Metr keeps

such

rec rds

in

an

empl yee ’s pers nnel file or not)

for

any

empl yee

placed n paid

or

unpaid

administrative leave fr m January 2012 to the present.

ESPO SE:

31. All credit-card statements fr m

N

related to c rp rate

cards

for all

appr ved Metr Health empl yees (fr m July 2013-December 2014).

ESPO SE:

32.

Rec rds regarding

discipline

of

any

empl yee for failing to c mply with

Metr Health

policies regarding

credit-card

use.

ESPO SE:

33.

Rec rds

regarding discipline of

any empl yee

for

theft of

B t x

or

ther

injectables.

ESPO SE:

34.

Rec rds

regarding payment for legal services

related

to Simps n Huggins

including

but

n t

limited

to

the

decision to place him n unpaid

administrative

leave.

ESPO SE:

35. The c mpetitive sealed pr p sal that created the three-year service contract

between

Metr Health

and

the

Advis ry

B ard

mpany.

ESPO SE:

36.

All

contracts

and

amendments

between

Metr Health

and the

Advis ry

B ard

mpany

fr m

2013-the present.

ESPO SE:

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37.

Rec rds sent to

the

Ohi Att rney General

’s

office regarding

delegating

signat ry auth rity fr m Akram B utr s to Walter Jones, Seni r Vice

President,

ampus

Transf rmati n.

ESPO SE:

38.

All

contracts

signed

by

Walter

J nes

fr m

Oct ber

1,

2014 to

Oct ber

31,

2015.

ESPO SE:

39.

Rec rds

fr m

the

Laws n

system

listing

all

direct

reports

to

raig

Richm nd

(including

race, job pay grade, annual

salary

(excluding

benefits),

and

annual

perf rmance bonus).

ESPO SE:

40.

Rec rds

fr m the Laws n system listing

all

Metr Health empl yees

with

pay

grade

36 (including race, job pay grade, annual

salary

(excluding benefits),

and annual perf rmance bonus).

ESPO SE:

41.

de of

nduct Statements for

2013-2015

for

Akram B utr s, Mary

Weir-

B ylan, Elizabeth Allen,

and Michael

Phillips.

ESPO SE:

42.

onflict of

Interest

Statements

for

2013-2015 for

Akram

B utr s, Mary

Weir-

B ylan,

Elizabeth

Allen, and Michael Phillips.

ESPO SE:

43.

Ethics

Statements for 2013-2015

for

Akram B utr s,

Mary

Weir-B ylan,

Elizabeth Allen, and Michael Phillips.

ESPO SE:

44. Rec rds of any reports submitted to the Ohi Ethics mmissi n

regarding

receipt

of free

B t x

injections

by

any Metr Health

empl yee

or

relative

of

a

Metr Health

empl yee.

ESPO SE:

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December 21, 2015


Subodh

Chandra

_ _ _ _ _ _ _ _ _ _ _

Sub dh

handra

(0069233)

Ashlie

ase

Sletvold

(0079477)

Harris n Blythe

(00093851)

THE

HANDRA

W

FIRM,

LL

1265 W. 6th St., Suite 400

leveland, OH

44113-1326

216.578.1700

Ph ne

216.578.1800

Fax




Coun el for

Plaintiff

Simp on

Huggin

III

ertificate

of ervice

I

certify that

the

ab ve

disc very requests were

submitted to

the

lerk

’

s Office to be

served

with

the Summ ns and mplaint.

bodh

Chandra_ _ _ _ _ _ _

One of the attorney for

Plaintiff

Simp on Huggin III







Complaint and Discovery Requests

Documents

Transcript of Complaint and Discovery Requests